Region 4 Develops EI Strategy to Improve Schedules

Environmental Indicators (EIs) are measures being used by the
RCRA Corrective Action program to go beyond programmatic activity
measures to track changes in the quality of the environment. A positive
"Current Human Exposures Under Control" EI determination indicates
that there are no "unacceptable" human exposures to "contamination"
(i.e., contaminants in concentrations in excess of appropriate risk-based
levels) that can be reasonably expected under current land- and
groundwater-use conditions at a facility site-wide. A positive "Migration
of Contaminated Groundwater Under Control" EI determination indicates
that the migration of "contaminated" groundwater has stabilized,
and that monitoring will be conducted to confirm that contaminated
groundwater remains within the original "area of contaminated groundwater"site-wide.

Defining a clear strategy for reaching positive EI determinations
is important because many facilities have yet to reach a positive
EI determination and the period of time in which a positive EI determination
must be reached is short. Region 4's EI Strategy involves the development
of an EI Project Schedule, with Milestones, for each facility. The
EI Project Schedule for a facility estimates when human exposures
and migration of groundwater contamination will be controlled AND
outlines EI Interim Milestones. The EI Project Schedule is a planning
tool - not an enforcement document.

The importance of establishing schedule dates for the completion
of each EI Interim Milestone is that it allows for the periodic
comparison to actual completion dates. Hence, each facility's (and
EPA or State project manager's) progress toward a positive EI determination
can be monitored and appropriate action can be taken to correct
unacceptable project delays. In addition, accurately tracking and
analyzing success in meeting positive EI determinations is particularly
important given that the GPRA goals for the program are that by
2005, 70% of high priority RCRA sites will have toxic releases to
groundwater controlled and 95% will have human exposure toxins controlled.

The RCRA Information System (RCRAInfo) will be used to track the
EI Interim Milestones in the unauthorized states in Region 4 (TN,
FL and MS). Specifically, a RCRAInfo area titled something similar
to "Environmental Indicator Project Schedule" is to be established.
RCRAInfo is also being used to identify which of the three (3) RCRA
Branches within the Regional Office is responsible for the RCRA
Cleanup Baseline Facility and/or responsible for tracking an authorized
State's progress toward a positive EI determination.

For authorized states in Region 4 (AL, GA, KY, NC, SC), the Regional
Office will obtain and track each State's estimates for attaining
their GPRA Goals. As in unauthorized states, if problems are observed
which might lead a State to not meet the annual or cumulative fiscal
year goals which the regional office is measured against, then the
problem can be identified and, where feasible, action can be taken
to correct the delay.

Because of the relatively short amount of time given to meet these
two EIs, Region 4 decided that these EI Project Schedules should
not be unilaterally determined without input from the facilities.
Therefore, each facility is receiving a copy of their draft EI Project
Schedule. Comments/suggestions on the Interim Milestones and estimated
completion dates can then be provided to the EPA or State Project
Manager prior to finalization of the EI Project Schedule. The regional
office maintains that active, ongoing and open communication with
the RCRA facilities is essential if human health and the environment
are to be protected and the EPA goals for GPRA are to be met in
a timely manner.